Is internal audit keeping up?

The risk landscape is changing faster than ever

boardroom of people
  • 5 minute read
  • October 29, 2026

Most internal audit functions still build their plan around an annual risk assessment. The latest Risk in Focus 2026/27 findings indicate that this approach is becoming increasingly difficult to justify. 

The report finds that rapidly evolving, interconnected risks are outpacing strategic decision-making, risk assessment, mitigation, and governance. As a result, annual risk assessments and audit plans can quickly become outdated, and limited internal audit time and resources need to be redirected as risks change. The question for boards and CAEs is therefore not only which risks matter most, but whether internal audit coverage can move as quickly as those risks do. 

Three risks, one connected problem 

Cybersecurity and data security remains the dominant risk, identified as a top five risk by 86% of CAEs. Digital disruption, new technologies, and AI moved from third to second place (52%), and macroeconomic and geopolitical uncertainty rose to third (51%).

The rankings themselves are not surprising. What stands out is how closely these risks are linked. The report notes that digital disruption, for example, increases the risk of data breaches, creates dependence on a small number of US technology suppliers, operates within a shifting regulatory environment and reshapes how people and AI interact. A geopolitical event can therefore become a cyber, third-party, and regulatory issue within weeks. Audit plans that treat each risk as a separate line item may miss where these risks meet. 

Risk landscape

Where audit effort and risk do not match 

The most useful part of the report for internal audit is its comparison of risk rankings with internal audit effort. Cybersecurity is the only area where the two are fully aligned, both ranking first. Outside cybersecurity, risk rankings, and audit effort are less closely aligned: 

Although this is the second-highest risk, internal audit coverage has not kept pace with AI adoption. Gaps in governance, training and assurance indicate that audit attention may still be insufficient relative to the risk. 

This is the third-highest risk, yet it receives relatively little audit attention. Coverage also tends to focus on the consequences of geopolitical events rather than whether organisations are prepared to anticipate and respond to them. 

Only 13% of CAEs ranked it among their top five risks, but it received the fourth-highest level of audit effort. This suggests that governance may be receiving more audit attention than its risk ranking alone would indicate. 

These mismatches should be interpreted carefully. Governance may warrant significant audit attention because it affects the management of all other risks. However, the report cautions that as urgent issues dominate board agendas, areas such as human capital and climate change risk may receive less scrutiny despite their continued significance. 

The annual plan is under pressure 

The report shows that many CAEs are already responding. Many have moved away from rigid annual audit plans and now use more frequent risk assessments to drive adaptable schedules, balancing regulatory requirements with urgent business requests. CAEs also report greater collaboration across the organisation, which helps them understand fast-moving risks while preserving internal audit’s independent judgement under the Three Lines Model. 

Agility, however, is not the same as reacting to whichever issue is most urgent. A plan that changes every quarter without clear criteria can be as weak as one that never changes. 

Our view – what a dynamic audit plan looks like in practice  

In our experience, functions that keep pace with their risk environment usually have four features in common: 

The risk universe is refreshed at least quarterly, and specific events, such as a new AI deployment, a significant supplier change or a new sanctions regime, trigger a reassessment outside that cycle.

Mandatory and regulatory reviews are protected, while a defined portion of capacity is held back for emerging risks and advisory work agreed with the audit committee. 

Instead of one audit per risk, engagements are scoped to test where risks overlap, such as third-party technology dependence across cyber, AI and geopolitical exposure. 

Areas that receive high effort each year, including cyber and governance, are tested to confirm the effort remains proportionate and linked to current threats, freeing capacity for areas where risk maturity is low. 

This also requires the right skills. Auditing AI governance or geopolitical scenario planning may call for technology, data, or sector expertise that a small function may not have in-house, making co-sourcing a practical option. 

Why this matters in Malta 

In Malta, particularly outside the regulated financial services sector, second-line functions are often less mature and internal audit teams tend to operate with lean resources. Risk registers may therefore not be updated frequently enough to capture emerging and rapidly changing risks, limiting internal audit’s ability to adapt its plan and assurance coverage at the required pace. Addressing this requires stronger second-line risk management, more dynamic risk registers, and targeted upskilling or co-sourcing to build capability in areas such as AI. Internal audit should also consider how AI can support leaner, more responsive risk assessment and audit delivery, while maintaining appropriate governance and oversight. 

Questions for boards and audit committees  Questions for chief audit executives 
  • When were the risk register and internal audit plan last updated following a significant change in risk? 

  • Does internal audit focus on today’s most important and connected risks, or mainly on areas reviewed in previous years? 

  • Can the second line identify and escalate new risks early enough? 

  • Does internal audit have the time and specialist skills needed to cover AI, technology, and geopolitical risks? 

  • Do we review changes in risk frequently enough to adjust the audit plan during the year? 

  • Have we agreed with the audit committee when the plan should change and how much capacity should be reserved for emerging risks? 

  • Can we rely on the information provided by the second line, and do we challenge it where necessary?  

  • Do we have the right combination of internal skills, external support, and responsible AI use? 

Closing thought 

Risk in Focus 2026/27 shows that internal audit is adapting, but not always at the same pace as the risk landscape. For organisations in Malta, a flexible audit plan is only part of the answer. Timely risk information, an effective second line, and access to the right skills are equally important. The key question for boards and CAEs is not only what internal audit covers, but how quickly it can respond when risks change.

Stay up to date with our latest

thought leadership

Contact us

Bonavent Gauci

Bonavent Gauci

Advisory Partner, PwC Malta

Tel: +356 2564 7090

Vyas  Isnoo

Vyas Isnoo

Senior Manager, Advisory, PwC Malta

Tel: +356 7975 6979

Follow us